We
wrote to the US Center for Disease Control (CDC) asking what level of Antimony exposure is safe.
We got a
reply from the CDC: “ATSDR [Agency for Toxic Substances & Disease Registry]
has not derived a chronic MRL [Minimal Risk Level] for antimony. However,
the U.S. EPA chronic oral reference dose for antimony is 4E-4 mg/kg/day.”
This is .0004 mg/kg/day, or 4/10,000’s of a milligram/ per kilogram of body
weight/ per day. This is a far different number than the CPSC assumption of
a safe level of 2.3 mg/kg/d. In fact, it is 5,750 times more than the EPA
minimal risk number. It also changes everything and proves our antimony
absorption from flame proof mattresses is unsafe by 27.5 times.

Comparing these numbers to the CPSC assumptions in their table 16, tab d, p
45, shows:

Parameter

Antimony (CPSC
Assumptions)

Antimony (CDC/ATSDR/EPA
numbers)

Difference
CPSC/EPA

ADD Total
(mg/kg/d) (Average Daily Dose)

0.011

0.011

ADI mg/kg/d
(Acceptable Daily Intake)

2.3

.0004

5,750

Hazzard Index,
HI (numbers below one are considered safe)

.005

27.5

5,500

CPSC tests prove we will absorb 0.011 mg/kg/d of Antimony from new flame
proof mattresses. The only question is what is a safe level? The CPSC says
2.3 mg is safe while the EPA says only .0004 is a safe level. If we accept
the EPA number it proves new mattresses are toxic by 27.5 times more than
the safe level.

Put another way, for
Antimony the US Environmental Protection Agency (EPA) says it's safe to
absorb only .0004 mg/per Kg of body weight/per day. Thus with the CPSC
assumption of an average person weighing 70 kg, or 154 lbs, the maximum safe
intake of antimony is only .028 mg per day according to the EPA for the
average person. Comparing the EPA safe number of .028 mg Antimony with the
CPSC saying we will absorb .802 mg shows flameproof mattresses toxic by 28
times safe level.

The CDC points out: “ATSDR has not derived a chronic MRL [Minimal Risk
Level] for antimony.” They can not derive one because as stated in their
health effects document on Antimony they say: “At the lowest exposure
levels tested, the adversity of the effects was considered to be serious.”

It seems clear the CPSC is trying to prove poison laden mattresses are safe.
There are many other problems with this risk assessment. Again over TERA’s
(the independent reviewer) objections they changed all the rules of the
child sucking test to obtain lower numbers. We believe Boric Acid would fail
a properly designed child sucking test, with realistic exposure data. This
test is designed to protect a one year old child. The CPSC did not even
consider children under five in their risk assessment.

The CPSC says: “As with any risk assessment, there are assumptions,
limitations, and sources of uncertainty. … It should be noted that
percutaneous [skin] absorption data were not available for antimony.” The
CPSC assumes a Percutaneous (Skin) absorption rate of only .002 per hour of
the chemical that has leached or migrated to the surface of our mattresses
and is in contact with our bodies. This is only 2/1,000’s of the available
chemical. This seems a very small number. The correct number might be much
higher and we may absorb much more than the CPSC calculations predict.

Antimony Trioxide accumulates in our bodies. When pressed by TERA about the
cancer risk from Antimony Trioxide the CPSC admits: “The cancer effects
are cumulative. Every exposure contributes to the overall lifetime risk of
developing cancer.”

The CDC and the EPA
has proven CPSC safety assumptions wrong. They have also proven CPSC
exposure and absorption calculations of poison absorbed from flame proof
mattresses will exceed toxic levels by 27.5 times.